Lead Paint and Bathroom Remodels in Pre-1978 Homes

Bathroom walls in older homes may have been repainted many times, because damp rooms peel. In a house built before 1978, the lower layers may contain lead. A bathroom remodel turns those layers into dust when walls, ceilings, trim and window casings are cut out or sanded, and in a small room that dust has nowhere to go. This page explains how Washington's lead renovation rules apply to bathroom work as of October 2026, and what lead-safe work should look like in a room that may be only a few feet across.

Who runs the program in Washington

Washington runs its own version of the federal Renovation, Repair and Painting (RRP) program. The Department of Commerce Lead-Based Paint Program provides "training, certification and compliance enforcement" under chapter 365-230 WAC. Commerce says a firm or individual needs RRP certification to "Offer, bid, or contract to work on pre-1978 properties", including "Home renovations", "Remodels", "Painting" and "Any work that disturbs paint in a pre-1978 property". Certificates "are valid up to 5 years."

The core rule is WAC 365-230-330(1): "Renovations must be performed by certified firms using certified renovators".

Why a small bathroom rarely qualifies as minor repair

WAC 365-230-310 excludes "minor repair and maintenance activities" that "disrupt six square feet or less of painted surface per room for interior activities", but only where no prohibited practices are used and the work "does not involve window replacement or demolition of painted surface areas."

That exception is narrower than it sounds for a bathroom:

• The limit is per room, not per wall. Six square feet is less than the wall area behind a typical vanity.
• Demolition is excluded at any size. Taking out a painted wall to reach a shower valve, removing a painted soffit over a tub, or tearing out a painted ceiling to reroute a fan duct is demolition of painted surface area.
• Window replacement is excluded. Replacing the bathroom window takes the job out of the exception.

What lead-safe work looks like in a bathroom

WAC 365-230-330(1)(a) and (b) set out what a certified firm must do. Here is how each one translates to a small room:

• Warning signs defining the work area. Expect them at the bathroom door and possibly at the end of the hallway.
• Containment so "no dust or debris leaves the work area". In a bathroom that usually means plastic sheeting sealing the doorway, with a flap or zipper for entry.
• Floors covered with taped-down plastic "six feet beyond the perimeter of surfaces undergoing renovation". In many bathrooms, six feet from the walls being worked on reaches past the door, so the hallway floor outside is often covered too.
• Ducts, windows and doors closed and covered. That includes the heat register and the exhaust fan opening. A fan running during demolition would pull dust into the duct and possibly the attic.

The pamphlet and your signature

WAC 365-230-320(1) requires that "No more than sixty days before beginning renovation activities in any residential dwelling unit of target housing, the firm performing the renovation must" give the owner the pamphlet. The firm must then get your written acknowledgment, or a certificate of mailing at least seven days before the work. The pamphlet is a specific document: "The Lead-Safe Certified Guide to Renovate Right" (WAC 365-230-310).

This is separate from the Notice to Customer every Washington homeowner receives on residential jobs of $1,000 or more, described in bathroom contracts and change orders.

How to check a firm

1. Ask for the Commerce certificate and check the firm name and expiration date.
2. Check Commerce's lists. Its Business and Homeowner Resources page has downloadable lists of certified RRP companies, alphabetical and by city and county, plus "Enforcement Action Records" and "Suspended and Revoked/Denied Companies".
3. Contact Commerce with questions: LBPInfo@Commerce.wa.gov or 360-586-5323.

If you do the work yourself

The state rule covers renovations "performed for compensation". The EPA says the RRP rule generally does not apply to homeowners working in their own pre-1978 homes, but it does apply if you rent all or part of the home, run a child care center there, or renovate homes for profit. The EPA also advises: "If you are unable to determine the age of your home, it's safest to assume the area you are renovating has lead-based paint."

Being outside the rule does not make the dust safer. Containment, covered floors and sealed ducts are the reasonable model for owners too. Other rules for owner-performed work are in doing part of your own bathroom remodel.

Lead in paint is not the same as asbestos

Older bathrooms can raise both, and they are regulated by different agencies. Lead is a Department of Commerce program focused on paint. Asbestos in Clark County falls under the Southwest Clean Air Agency and L&I and concerns materials such as old vinyl flooring, adhesives and textured coatings. A lead certificate does not cover asbestos work. See asbestos in old bathroom tile, vinyl and mastic.

Where JDI fits

If your home predates 1978, mention it at the first conversation with any contractor, including us, and ask how the firm will handle lead-safe work in your bathroom. JDI offers a free in-home consultation; you can start on our Vancouver bathroom remodeling page.